I've lately come upon two State Historic Preservation Officers (SHPOs) who insist that all correspondence with them be carried out via hard-copy letters and attachments -- no emails or attached electronic documents.
When I cornered a staff member of one of the offices and inquired about this seemingly retrograde and anti-environmental policy -- which wastes time and money, complicates digital file management, and requires the killing and processing of trees with all the attendant environmental impacts -- I was told that it was standard policy at most if not all SHPO offices, and necessary in order to maintain a "paper trail."
The latter argument is idiotic, of course; innumerable federal agencies maintain "paper trails" in electronic contexts. I can't remember the last time I had to file my tax returns on paper, for example, and the Advisory Council on Historic Preservation routinely corresponds electronically about Section 106 cases. But I wouldn't put it past the National Park Service to have demanded the maintenance of paper files by its Historic Preservation Fund (HPF) grantees.
Can anyone enlighten me about this? Do most SHPOs promote deforestation? Is it mandated by HPF grant administration policy?
Tom King’s CRM Plus -- Ruminations on "cultural resource management," environmental impact assessment, and related esoteric topics, by a curmudgeon who seldom has anything good to say about anything.
10 comments:
SHPOs need to be able to disclaim their bad calls that cost project proponents time and money. That's why some prefer paper - it isn't broadcast in cyber space and not nearly as prone to boomerang back. Electronic mail is permanent and unforgiving. Paper is harder and slower for checking the record. Paper is inconvenient and slow, and the audience is tightly controlled. Paper and snail mail are simply better for selective memory and deniability. If one is never wrong, and always right - paper is preferred. Trees don't have anything to do with it.
But, does this really matter ? SHPOs are not accountable for anything they ever say, so the mode of communication shouldn't really matter in the end. SHPO consultations are a formality, but of no real consequence. Paper makes it slower to check the box, which is the only purpose of correspondence with SHPOs.
And, glad to see you are back on the beat. Welcome back.
Wow, Anon, you're even more cynical than I. That's scary, but maybe I'm just off my game. Thanks.
Certain federal agencies have been able to develop working electronic record retention systems because they have funding, IT support, and access to extremely well paid federal contractors. It’s not a simple thing to have smoothly operating scanners, servers, databases, almost unlimited storage, and reliable backup. The SHPOs I have worked for and with have been lucky when they have 5-year old computers and functioning email.
Fair enough, Anon, and I suppose we can all be sympathetic with the woes of SHPOs (There's a song title). But it strikes me that setting up and maintaining an e-filing system is no harder than using a paper-based one, and can offer significant managerial efficiencies. As for scanning, if you get stuff electronically you shouldn't need to scan it, and anyhow, one can get a really good scanner for well under a thousand bucks (I've bought and am using one). To say "oh dear, poor me, I have such antiquated and inefficient equipment and procedures that I simply have no choice but to continue to use them and impose them on others" strikes me as an admission of incompetence.
Woes of SHPOS...I'll work on that r :) "Shuppose a SHPO Had Some Woes...."
Hi Tom,
Graduate student and long time fan (since learning about CRM), working with the West Virginia SHPO right now. They require that I file everything in Paper for NR nominations and survey forms. (They then scan these into a digital database). Why I can't send these as a digital file is beyond me.
That's pretty much what I was told, too -- "we can scan it into a database, but we gotta get it in hard copy." It's like they don't know it can just as easily work the other way -- that one can print a hard copy from a digital file if need be. Very strange.
The problem is depending upon the state, they have underlying archival requirements the SHPO does not have full control over. They cannot rely on electronic files because there is no state sanctioned electronic file management system for their classification of documents. This means if you send a digital file, the SHPO must print it to submit it for the record anyway. Depending on the volume of their correspondence, and the status of their budget, this adds an additional burden.
Does anybody have any advice for an office trying to go paperless? I would love to maintain an electronic paper trail and get rid of these stacks of reports covering all the flat surfaces in my vicinity, but our IT resources are limited and I will have to come up with this myself.
SHPO person here, specifically 106 and state compliance. We've transitioned to doing the majority of our consultation electronically, especially with state and federal agencies with whom we regularly correspond. We still receive a lot of paper mail, though. A couple of things come to mind as to why SHPO's have been slow to join the madding crowd of the modern world (in addition to old, sub-par equipment, which is certainly a problem).
1. State government retention requirements. We still have to print and maintain some project records for X amount of time, due to retention requirements and the tenants of open records laws. These variables are beyond our control at this level of government, and it took a LONG time to get our leadership to consider allowing us to formally consult via email and PDF documentation.
2. Bad contact information, or too much contact information, in consultation materials. Sometimes email addresses are incomplete, incorrect, or unclear as to who the recipient is. In these cases, it's safer to send a hard copy.
Unfortunately as I mentioned, we're still stuck in a world where we have to retain paper copies of most formal communication, even when it's sent electronically. We're also working on a transition to electronic records storage (which is allowable under retention guidelines and state law), but no funds have been allocated for developing that system so we're relying on the heroic efforts of two people (me and one other guy) who have the database management and coding skills to create a database that can manage what we need (in addition to e-filing, we have to think about the arcane requirements of NPS reporting, and actual useful reporting for our own internal purposes). Let's not forget the need to work with an overburdened IT department and off-site or cloud storage venders to keep the stuff safely ensconced in the digital record.
On a side note, anon number one seems pretty angry at SHPOs. I can't speak for all of them, but here we have our feet pretty well cemented in the real world. We get our reviews done on time, most of the time, and work hard with project proponents to reach good outcomes. Cynicism has it's place, but there's a fine line between cynical and bitter.
Cheers, Tom.
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